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The regulation isn't the hard part. Proving you met it is.
Regulation (EU) 2023/1230 replaces the Machinery Directive and applies from 20 January 2027. Most of what it asks of technical documentation is familiar. What's new sits in Article 10(7).
10 years
Minimum availability
Documentation stays online for the machine's expected lifetime, and no less than ten years.
1 month
Paper fallback
A free paper copy, supplied within one month of a request.
5
Binding requirements
Each one an infrastructure requirement, not a documentation one.
The question is not whether your company has to communicate compliance to dealers and customers. The question is how your team does that at scale, in several languages and with proof, using the headcount you already have.
Source: Regulation (EU) 2023/1230, Article 10(7). General guidance only; see the note at the end of this page.
Digital is permitted, not simplified
Article 10(7) allows instructions in digital form, then defines what that means. The conditions are harder to meet than the paper ones.
Ten-year availability
All documents stay accessible online for the machine's expected lifetime, and no less than ten years from placing on the market. The version current at delivery is the one that counts.
Common gap: no operational plan for year eight or year ten.
Unique identification
A direct access reference on the machine, its packaging, or the accompanying document, linking to that machine's documentation.
Common gap: a static QR code pointing at a PDF. It breaks at the next website migration.
Format
Common gap: an online viewer without a download option.
Paper fallback
A free paper copy on request, supplied within one month.
Common gap: no defined process, effort, or owner for the one-month deadline.
Tamper-proof archiving
Released versions can't be altered, overwritten, or deleted without a record.
Common gap: a document system without write-once storage or a complete audit trail.
A portal outage is the legal equivalent of a missing instruction manual. That makes high availability an obligation, not a technical preference.

Digital provision means ten years — stable, versioned, and provable, with the document that was current at delivery. Not "upload once." Not "put it on the website."
Why the usual approaches fall short
Three plans come up in almost every conversation with manufacturers. None of them reliably meets the regulation.
PDFs on the corporate website
Where it breaks
The next website migration kills the QR codes on machines already delivered.
Corporate sites follow the marketing lifecycle, with a redesign every three to four years, new URLs, and often a new CMS. There's no versioning, no audit trail, and no one responsible for availability in year eight.
The ERP portal on its own
Where it breaks
Dealers who aren't in your ERP have no access.
The regulation requires access for every operator of the machine, not only ERP contacts. ERP portals rarely keep a document-level audit trail, and serial-number QR routing isn't a standard ERP capability.
Custom development by internal IT
Where it breaks
Authentication, multilingual delivery, and ten-year operations get underestimated at scoping.
Custom builds start as projects and become permanent ones. Scoping errors surface as budget overruns, and internal IT is rarely set up for ten years of operational responsibility, with no SLA behind it.
One source of truth, in two levels
A machine documentation portal replaces the email chain with one self-service access point, on a lifecycle independent of your marketing website. One level meets the regulation. The other creates value.
Email and PDFs
Sent, not proven
No version control, no audit trail, no continuity. Old PDFs keep circulating after every change.
One source of truth
Current and provable
Dealers look up documentation themselves — machine by machine, in their language, always current. Every access is on record.
Level 1: the legal obligation
Public, with no login and no paywall. Any dealer, end user, or inspector reaches the required documentation without a barrier.
Instruction manuals as PDF
Downloadable, storable locally, printable, and platform-independent.
EU Declaration of Conformity
Versioned, with a release date and tamper-proof archiving.
QR routing to the machine page
Dynamic URLs that stay valid through server migrations, with serial numbers mapped to type-specific documentation.
Serial number search
Direct access by serial number, not a generic search form.
Plain-text URL fallback
A short web address beside the QR code, for entry without a camera.
Ten-year tamper-proof archiving
A timestamped audit trail of creation, release, and access.
Language switching
Output in the official language of the delivery country.
Paper copy on request
Triggered from CRM or ERP, printed on demand, delivered within one month.
Level 2: the return
Registered access via double opt-in. It isn't required by law. It's the return on the compliance investment.
Firmware and software updates
Dealers are notified when new versions are released, with no manual distribution.
CAD files, STEP files, and EPLAN macros
Downloads for OEM partners and technical integrators, with fewer support requests.
Individual calibration certificates
Serial-number-specific certificates on demand, which relieves technical customer service.
Interactive exploded-view diagrams
A direct path to the spare parts shop from inside the documentation.
Service tickets and maintenance history
Tickets created in the portal, with the history visible to the dealer and connected to the CRM.
Identified operators
Who operates which machine, under which serial number.
Two things sit outside any portal:
- Metadata discipline: every document linked to part numbers, production years, machine types, and serial numbers.
- QR codes printed on the type plate in weather- and abrasion-resistant industrial quality.
No portal compensates for a code that has worn off.

Counting back from go-live
A first phase runs about 24 weeks end to end. The phases are sequential, so the lead time matters more than the date.
01
Decision and commissioning
Internal sign-off and vendor selection.
02
Concept and data mapping
Machine types, serial number logic, and language versions.
03
Implementation and integration
Portal build, CRM connection, and QR routing.
04
Testing and acceptance
QR codes tested, audit trail verified, and paper fallback tested.
05
Go-live and training
The portal goes live, and your team is trained.
T is the day the portal has to be live. For most manufacturers, that's the day the first machine ships with a QR code on its type plate.
Start with a pilot. One or two machine types and one dealer group, running within a few weeks. It gives you a working proof of concept to test with real dealers. It also answers the question an inspector will ask: show me that the QR code on a machine delivered last month works today.
What the plan involves
Scoped around your machine types, your dealer network, and the systems you already run.
Pilot
One or two machine types and one dealer group, running within a few weeks. Level 1 first, Level 2 optional.
Lead time
About 24 weeks for a first phase, counted back from go-live.
Your input
Serial number logic and your current documentation. Nothing else to prepare for the first call.
Systems
- Customer and machine data (CRM): usually already in place.
- Portal and web platform: usually the only new component.
- Marketing automation and web analytics: depending on your setup.
Build-out
Compliance comes first. Next come operator identification, update and recall communication, and audit preparation and usage analysis, each triggered by real events.
Scope boundary
Machine classification, risk assessment, and CE conformity assessment stay with your CE consultant or technical writing agency. We provide the portal infrastructure. The two are complementary.
Built for manufacturers with a distribution network to manage
Four situations this plan is built to solve.
An active dealer or distributor network
You're not shipping direct-to-end-customer only. Documentation has to reach partners you don't fully control.
Multiple machine types, markets or languages
A specification change doesn't mean one email. It means version tracking across models and locales.
Compliance that lands on marketing
Engineering signs off the content. Someone else has to handle the rollout, without added headcount or budget.
No dedicated documentation infrastructure yet
You're still relying on the corporate website, your ERP, or a plan to build it internally.

Which part of this is still unsolved for you?
Bring your machine types and your current setup. We'll scope it with you.
Built for the part documentation tools leave out
Most systems help you produce documentation. We help you distribute it, version it, and prove it.
30+ years of experience
Digitalizing customer relationships for mid-sized and large organizations.
Trusted by 4,000+ companies
Global manufacturers, luxury brands, and public infrastructure run on JustRelate.
One platform, no integration work
Email, web, CRM, marketing automation, CPQ, portals, and analytics in one system. It connects to your existing stack without a rip-and-replace.
European by design
Built, hosted, and supported in Europe, with teams in France, Germany, and Poland.
Questions about the EU Machinery Regulation
Clear answers to the questions manufacturers ask before they book.
It allows manufacturers to provide instructions in digital form and defines what that means. There are five binding requirements:
- availability for the machine's expected lifetime and no less than ten years
- a unique access reference on the machine
- a downloadable, printable format
- a free paper copy within one month of a request
- tamper-proof archiving of released versions
It allows manufacturers to provide instructions in digital form and defines what that means. There are five binding requirements:
- availability for the machine's expected lifetime and no less than ten years
- a unique access reference on the machine
- a downloadable, printable format
- a free paper copy within one month of a request
- tamper-proof archiving of released versions
Regulation (EU) 2023/1230 applies from 20 January 2027 to every manufacturer placing machinery on the EU market, with no size threshold. It replaces Machinery Directive 2006/42/EC. As a regulation, it takes effect in every member state without national implementation.
Regulation (EU) 2023/1230 applies from 20 January 2027 to every manufacturer placing machinery on the EU market, with no size threshold. It replaces Machinery Directive 2006/42/EC. As a regulation, it takes effect in every member state without national implementation.
Neither reliably meets the regulation on its own. Website redesigns and new URL structures break QR codes on machines already delivered. ERP portals exclude dealers and end users who aren't in your ERP, and they rarely keep a document-level audit trail.
Neither reliably meets the regulation on its own. Website redesigns and new URL structures break QR codes on machines already delivered. ERP portals exclude dealers and end users who aren't in your ERP, and they rarely keep a document-level audit trail.
A first phase runs about 24 weeks end to end, counted back from go-live. With JustRelate, concept and data mapping take 3–4 weeks, implementation 4–6 weeks, testing 2–3 weeks, and the rollout one week. A pilot with one or two machine types and one dealer group runs within a few weeks.
A first phase runs about 24 weeks end to end, counted back from go-live. With JustRelate, concept and data mapping take 3–4 weeks, implementation 4–6 weeks, testing 2–3 weeks, and the rollout one week. A pilot with one or two machine types and one dealer group runs within a few weeks.
Usually not. The portal combines four capabilities: customer and machine data, a portal platform, marketing automation, and web analytics. Most manufacturers already run three of them, so the portal platform is typically the only new component.
Usually not. The portal combines four capabilities: customer and machine data, a portal platform, marketing automation, and web analytics. Most manufacturers already run three of them, so the portal platform is typically the only new component.
No. Machine classification, risk assessment, and CE conformity assessment stay with your CE consultant or technical writing agency. JustRelate provides the portal infrastructure. The two are complementary.
No. Machine classification, risk assessment, and CE conformity assessment stay with your CE consultant or technical writing agency. JustRelate provides the portal infrastructure. The two are complementary.
No. Level 1, which is public with no login, meets the regulation. Level 2, with registration via double opt-in, is optional. It turns anonymous downloads into identified operators, which enables targeted firmware notices, safety advisories, spare parts sales, and service outreach.
No. Level 1, which is public with no login, meets the regulation. Level 2, with registration via double opt-in, is optional. It turns anonymous downloads into identified operators, which enables targeted firmware notices, safety advisories, spare parts sales, and service outreach.
Start with a 30-minute expert call
We bring a technical expert and look at your specific stack. No presentation — we build on screen.
Bring us your situation, and we'll scope it with you. Nothing to prepare: no technical documentation, no system specification.
0–5 min
Live demo
A working portal built for a comparable machine manufacturer. You see the QR code on a type plate, the page it resolves to, the audit trail, and a Level 2 operator record in the CRM.
5–15 min
Scope mapping
Your machine types, dealer group size, how often specifications change, and which languages your network needs. Questions, not homework.
15–25 min
Build logic
Which capabilities are involved, what you configure and maintain, and what we set up once at the start.
25–30 min
Pilot definition
A starting point scoped together, typically one or two machine types plus one dealer group, and what a first working version would take.